The Delhi High Court has held that an unverified internal police report - which on its face states it is solely for reference by investigating officers and must be verified by the concerned police station - cannot be treated as proof of a person's involvement in a criminal case where that person is not named in the FIR. The Court directed the DCP, IGI Airport to verify the database entry against the records of the relevant FIRs and, if erroneous, correct it and communicate the outcome within four weeks, while restraining reliance on the report in any court proceeding until verification is complete.
Background & Facts
The Dispute
The petitioner, Amrinder Singh, approached the Delhi High Court seeking quashing of FIR No. 215/2025 registered at Police Station IGI Airport, New Delhi, and all consequential proceedings emanating therefrom insofar as they relate to him. He also sought a direction that the internal Previous Conviction/Involvement Report No. 5848009 dated 14.05.2026, which links him to that FIR, be not relied upon and that the database entry be corrected.
Key Facts
- 05.03.2025: FIR No. 215/2025 registered at PS IGI Airport under Sections 318(4), 336(3), 340(2) of the Bharatiya Nyaya Sanhita, 2023 read with Section 12 of the Passports Act, 1967. The FIR initially named only one person: Dharampal Singh. The petitioner is not named in the FIR.
- 14.05.2026: Internal Previous Conviction/Involvement Report No. 5848009 generated. The report shows an entry attributing FIR No. 215/2025 to the petitioner only under the head "From Criminal Attributes DataBase" against TIN No. 0816902TP00006822.
- Under every other head - "From Crime Criminal Information System", "From Online Criminal Dossier", "From Register No. 9(iii)", and "From CAS DataBase" - the report records "Not Found / No Row Selected".
- The report bears an explicit disclaimer: it is "intended solely for reference by investigating officers", "must be verified by the concerned police station", and is "not to be submitted in court or to any other government office or agency".
- The report was placed on record in the petitioner's anticipatory bail proceedings arising out of FIR No. 827/2025, PS IGI Airport.
- Bail Application No. 4093/2026 (anticipatory bail in FIR No. 827/2025) is pending before the Delhi High Court.
Procedural History
- 28.10.2026: W.P.(CRL) 3359/2026 and Crl.M.A. 33556/2026 heard and decided by the Delhi High Court (Hon'ble Mr. Justice Sachin Datta).
- Learned ASC Mr. Amol Sinha accepted notice on behalf of the State.
- The Court disposed of the petition with directions.
Relief Sought
The petitioner sought: (a) quashing of FIR No. 215/2025 and all consequential proceedings qua him; (b) a direction that Internal Report No. 5848009 dated 14.05.2026 be not relied upon; and (c) correction of the database entry linking him to the FIR.
The Legal Issue
The central question was whether an unverified internal police database report - which explicitly disclaims evidentiary value and shows the petitioner's name only under a single database head while other systems return "Not Found" - can be treated as proof of the petitioner's involvement in an FIR where he is not named as an accused, particularly when such report is placed before a court in anticipatory bail proceedings.
Arguments Presented
For the Petitioner
Mr. S.P. Singh and Mr. Harmeet Singh, Advocates for the petitioner, contended that the petitioner is not named in FIR No. 215/2025 and no material has been placed on record to show he has been arrayed as an accused therein. The internal report relied upon by the prosecution is unverified, carries an explicit disclaimer against its use in court, and shows the petitioner's name only under one database head while four other systems return no record. Reliance on such a report in anticipatory bail proceedings is impermissible and prejudicial.
For the Respondent
Mr. Amol Sinha, ASC (Criminal), along with Mr. Kshitiz Garg, Mr. Anshul Sharma, Mr. Nitish Dhawan, and Mrs. Chavi Lazarus, Advocates for the State, accepted notice. The State did not seriously contest the unverified nature of the report or the petitioner's absence from the FIR. Inspector Rakesh Kumar, PS IGI Airport, was present.
The Court's Analysis
The Court first observed that since the petitioner is not named as an accused in FIR No. 215/2025, and nothing has been placed on record to show that he has been arrayed as an accused therein, there is no occasion for quashing the said FIR qua the petitioner at this stage. The remedy of quashing under Section 482 CrPC (or inherent powers) is not attracted where the petitioner is not an accused in the FIR.
The Court then turned to the internal report. A perusal of Report No. 5848009 showed that the entry attributing FIR No. 215/2025 to the petitioner figures only under the head "From Criminal Attributes DataBase". Under every other head - "From Crime Criminal Information System", "From Online Criminal Dossier", "From Register No. 9(iii)", and "From CAS DataBase" - the report records "Not Found / No Row Selected".
Critically, the report itself states it is "intended solely for reference by investigating officers", "must be verified by the concerned police station", and is "not to be submitted in court or to any other government office or agency". The Court held that such an unverified internal report, which on its own showing is not meant for judicial proceedings, cannot be treated as proof of involvement in a criminal case.
"Further, an unverified internal report which, on its own showing, is intended 'solely for reference by investigating officers', 'must be verified by the concerned police station', and is 'not to be submitted in court or to any other government office or agency', cannot be treated as proof of involvement in a criminal case."
Accordingly, the Court directed the concerned DCP, IGI Airport to verify the database entry (Annexure P-8) from the records of FIR No. 215/2025 and, if necessary, FIR No. 551/2019. The petitioner was directed to cooperate in the exercise. If the entry is found to be erroneous, it shall be corrected and the outcome communicated to the petitioner within four weeks. Until verification is completed, Report No. 5848009 (Annexure P-8) shall not be relied upon or placed before any Court as proof of the petitioner's involvement in FIR No. 215/2025.
The Verdict
The petition was disposed of with the following operative directions: (1) The DCP, IGI Airport shall verify the database entry (Annexure P-8) from the records of FIR No. 215/2025 and, if necessary, FIR No. 551/2019; (2) The petitioner shall cooperate in the verification exercise; (3) If the entry is found erroneous, it shall be corrected and the outcome communicated to the petitioner within four weeks from 28.10.2026; (4) Until verification is completed, Report No. 5848009 shall not be relied upon or placed before any Court as proof of the petitioner's involvement in FIR No. 215/2025; (5) The pending application (Crl.M.A. 33556/2026) stands disposed of. No order for quashing of FIR was passed as the petitioner is not named therein.
What This Means For Similar Cases
Unverified Internal Reports Lack Evidentiary Value
Police reports that carry explicit disclaimers stating they are for internal reference only, require verification by the concerned police station, and are not to be submitted in court cannot be treated as proof of criminal involvement. Practitioners should object to the placement of such reports in judicial proceedings, particularly in bail hearings where they may prejudice the accused.
- Challenge any internal police report that bears a disclaimer against judicial use.
- Cross-examine on the verification status of database entries.
- Seek directions restraining reliance on unverified reports pending verification.
Database Entries Must Be Corroborated Across Systems
A database entry appearing under only one head (e.g., Criminal Attributes DataBase) while other systems (CCIS, Online Criminal Dossier, Register No. 9(iii), CAS DataBase) return "Not Found" is inherently unreliable. The Court's insistence on verification against actual FIR records establishes that database entries are not self-authenticating.
- Demand production of the underlying FIR and charge sheet to corroborate database entries.
- Argue that single-source database hits without cross-system verification are insufficient for adverse inferences.
Anticipatory Bail Proceedings Require Verified Material
When an unverified internal report is placed before a court in anticipatory bail proceedings, the court can and should direct verification and restrain reliance until verification is complete. This protects the accused from prejudice based on unverified police records.
- In anticipatory bail applications, object to annexures that are unverified internal police reports.
- Seek interim directions that such reports not be relied upon pending verification.
- Request the court to direct the concerned DCP/ACP to verify and correct erroneous entries within a fixed timeline.
